THE LONGEST SUMMER- DESPERATELY SEARCHING

     THROUGHOUT JULY OF 2006 I SEARCHED FOR ANYTHING THAT MIGHT BE OF HELP TO DEFEND US.  THOUGH I HAD NO IDEA HOW THIS LAWSUIT WOULD PLAY-OUT, 6 INCHES?, AFTER READING ABOUT ADVERSE POSSESSION AND ARLENE TELLING ME THIS IS NOT ABOUT 6 INCHES, I BEGAN TO THINK IN BIGGER DIMENSIONS.  THE SURVEY PIN WAS 7 FEET INTO THE WIDTH OF OUR 9 AND HALF FOOT WIDE DRIVEWAY.  BUT, NO WAY ARLENE, THERE IS NO POSSIBILITY THAT "SUBSTANTIALLY EXPANDED" MEANS ANYTHING MORE THAN 6 INCHES.   IN ANY CASE, I SAVE EVERYTHING, TO THE ANNOYANCE OF SOME, BUT YOU NEVER KNOW WHEN YOU MIGHT NEED IT.  OK, I FOUND THE "DEAR NEIGHBOR"  LETTER FROM  1979.  I LOOKED THROUGH EVERY PICTURE THAT WAS TAKEN.  I SEARCHED EVERY PIECE OF PAPER, AND THERE WERE FAR TO MANY.  I CONSIDERED, DID ANYBODY ELSE TAKE A PICTURE, A FRIEND, A NEIGHBOR, A RELATIVE, A BANK?  I FOUND A PICTURE FROM OUR REFINANCING IN 1994, A STREET SCENE, SHOWING OUR DRIVEWAY BUT IT HAD A COATING OF  SNOW ON IT.  IT DIDN'T APPEAR THAT IT WOULD BE ANY HELP, IT WAS A BAD COPY IN BLACK AND WHITE.  DID THE NEIGHBORS REFINANCE?  WOULD THEY HAVE PICTURES FROM THE REFINANCING?   TODAY I CAN,  WITH THIS COMPUTER,  GO TO THE WESTMORELAND COUNTY COURTHOUSE AND FIND OUT EXACTLY WHEN SOMEBODY REFINANCED .  BUT IN 2006 ALL I COULD  DO WAS GUESS. I FOUND SOME PRE-BLAST SURVEY PICTURES FROM THE TIME WHEN THEY WERE THINKING OF MINING COAL ON THE ACREAGE ABOVE US .  THE NEIGHBORS PROBABLY HAD THEM TAKEN OF THEIR PROPERTY TOO.
   ON JULY 12TH 2006 I WENT TO THE ROSTRAVER TWP MUNICIPAL BUILDING TO SEE THE MAPS ON CATHERS SUBDIVSION AND THE ORIGINAL SURVEY THEY HAD DATED 4-10-1989. WHILE I WAS THERE I TALKED TO THE ROSTRAVER TWP ZONING OFFICER AND THE ROSTRAVER POLICE.  SOMEHOW, I FELT THE NEED TO KNOW ABOUT THE LAW CONCERNING SECURITY CAMERAS.
   I WENT TO FIRST FEDERAL SAVINGS AND LOAN ON JULY 17TH TO SEE ABOUT THE POSSIBILITY OF ANY PICTURES FROM 1978 WHEN WE BOUGHT OUR PROPERTY. AND OF COURSE THEY WERE HELPFUL AND TOLD ME YORK REALTY IN WASHINGTON PA. MAY STILL HAVE THE PICTURES.  BUT I WAS ALSO SHOWN THE ORIGINAL COLOR PICTURES FROM THE 1994 APPRAISAL. WOW, STILL SNOW, BUT YOU CAN SEE  MORE DETAIL NOW.  MR. SALKO SAID THEY COULD BE GIVEN TO MY ATTORNEY.
   I ALSO TALKED ARLENE INTO GOING TO HALF PRICE BOOKS IN BETHEL PARK, PA. YES, I LIKE BOOKS.  TO KEEP UP WITH LEGALESE I BOUGHT " BLACK'S LAW DICTIONARY.  THEN, BECAUSE , I BOUGHT " ELEMENTS OF CIVIL PROCEDURE" AND "THE LITIGATION PARALEGAL".
   IN BLACK'S LAW DICTIONARY UNDER  ADVERSE POSSESSION I READ, " IN ORDER TO ESTABLISH TITLE IN THIS MANNER, THERE MUST BE PROOF OF NON PERMISSIVE USE WHICH IS ACTUAL, OPEN, NOTORIOUS,  EXCLUSIVE AND ADVERSE FOR THE STATUTORY PRESCRIBED PERIOD."
   ON JULY 20TH 2006 ARLENE AND I HAD AN APPOINTMENT  AT SHIRE LAW FIRM. ARLENE NEEDED TO GET HER NAME CHANGED ON OUR DEED.  I TOLD MR. SHIRE THAT FIRST FEDERAL HAD ORIGINAL COLOR PICTURES FROM 1994 AND I SIGNED A RELEASE TO GET THEM.  I GAVE MR. SHIRE THE SURVEYS I GOT THAT THE CATHERS HAD DONE ON 4-10-1989 AND 12-8-1989.  MR. SHIRE ASKED US IF IT WAS OK TO MAKE ORAL ARGUMENTS ON PRELIMINARY OBJECTIONS AND WE AGREED.  AFTER TALKING ABOUT  ANOTHER ISSUE , WITH MY " NEIGHBOR LAW" BOOK IN HAND, I OPENED IT UP AND POINTING, SAID, " I THINK I GOT THIS", REFERRING TO ADVERSE POSSESSION.  MR. SHIRE REALLY DIDN'T SAY ANYTHING, BUT, HE DID WRITE IT DOWN.  I CAN IMAGINE HIM THINKING, '' THINKING IT IS  ONE THING, BUT PROVING IT  IS ANOTHER MATTER ENTIRELY.''